AMELING, Philip Ray B.March 2, 2015

LABOR RELATIONS

Golden Donuts, Inc. v. NLRC [G.R. Nos. 113666-68, January 19, 2000.]

Facts: Private respondents were the complainants in three consolidated cases submitted with the Labor Arbiter. Complainants were members of the KMDD-CFW whose CBA with the corporation expired. During the negotiations, the management panel arrived late causing the union panel to walk out. The management addressed a letter of apology to the union and requested for negotiations to resume. The union panel did not show up despite letters from management advising the former of the CBA meetings. The union struck. A complainnt was filed by Golden Donuts to declare the strike illegal. Counsel for the union and strikers pleaded for a compromise whereupon both parties would desist from continuing their cases against each other. The Labor Arbiter rendered a decision upholding the dismissal of private respondents and ruling that they were bound by the compromise agreement entered into by the union with petitioners. Private respondents appealed to the NLRC, claiming that the union had no authority to waive or compromise their individual rights and they were not bound by the compromise agreement entered into by the union with petitioners.

Issue:Whether a union may compromise or waive the right to security of tenure and money claims of its minority members, without the latters consent.

Ruling:No. Absent a showing of the unions special authority to compromise the individual claims of private respondents for reinstatement and backwages, there is no valid waiver of the aforesaid rights. The judgment of the Labor Arbiter based on the compromise agreement does not have the effect of res judicata upon private respondents who did not agree thereto since the requirement of identity of parties is not satisfied. A judgment upon a compromise agreement has all the force and effect of any other judgment and is conclusive only upon parties thereto and their privies. Private respondents have not waived their right to security of tenure nor can they be barred from entitlement of their individual claims. Since there was no evidence that private respondents committed any illegal act, petitioners failure to reinstate them after the settlement of the strike amounts to illegal dismissal.